Attorney general opinion
Cash advance app rules in Arizona
Arizona has no earned wage access statute; a Dec. 16, 2022 Attorney General opinion says no-interest, non-recourse EWA is not a "consumer loan" requiring a consumer lender license.
From official sources, checked 2026-10-18.
- Status
- Attorney general opinion
- In effect since
- —
- License or registration
- No license or registration specific to these products
Fees
- Per the opinion, a provider may charge fees listed in A.R.S. 6-635 without the product becoming a "consumer loan", because those fees are excluded from "finance charge" (A.R.S. 6-601(11)).
Other rules
- Summary answer: "No. An EWA product that is offered as a no-interest and non-recourse product does not fall within § 6-601(7)'s definition of 'consumer loan'."
- Non-recourse, as defined in the opinion: no legal or contractual right to repayment, no debt collection, no sale of unpaid balances, and no credit bureau reporting.
- EWA bills that would add a new Chapter 18 to Title 6 (SB 1273 in 2024, SB 1582 in 2025, HB 2309 in 2026) were found. The current A.R.S. Title 6 index shows no Chapter 18.
Enforcement and official actions
- 2022-12-16 Arizona Attorney General, opinion. Attorney General Opinion No. I22-005 (R22-011), issued to Sen. Jeff Weninger: no-interest, non-recourse EWA is not a consumer loan, so no consumer lender license is required. Official document
A complaint or lawsuit contains allegations; it is not a finding unless a court or agency says so.
What we could not confirm
- Final status of HB 2309 (2026): the bill status page was not checked. The A.R.S. index shows no EWA chapter.
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Sources
- Arizona AG Opinion I22-005 (R22-011)
- A.R.S. Title 6 index (Arizona Legislature)
- HB 2309 (2026), introduced version
Checked 2026-10-18. Not legal advice.